Representation by Morecambe Wind Limited (Morecambe Wind Limited)
- Date submitted
- 10 July 2024
- Submitted by
- Members of the public/businesses
ScottishPower Renewables (WoDS) Ltd and Orsted West of Duddon Sands (UK) Ltd jointly own West of Duddon Sands Windfarm and Morecambe Wind Limited, which holds the generation licence. West of Duddon Sands is an operational offshore windfarm with a s36 Electricity Act 1989 consent and relevant marine licences (“our Development”). Its proximity to Morgan Offshore Wind Farm (“MOWF”) can be seen in MOWF’s Environmental Statement (the “ES”) (F2.9 Figure 9.4 and Table 9.8). Our Development does not object to the principle of MOWF however we do at present require to object to certain elements of it where we may wish to participate in the DCO Examination to make representations about the potential impacts on and interactions with our Development and, where appropriate, to secure appropriate mitigations. Concerns were previously highlighted to MOWF via a s48 consultation response and subsequent meeting. Our concerns as raised in the s48 response remain extant and we expect further meaningful engagement to seek to address the issues raised below and previously. We are open to addressing such matters within or outside the Examination process. Our Development expects to continue to operate and be maintained in the long-term. It may be upgraded and repowered in future, and will then be decommissioned. Co-existence with our Development must be considered and protected over the long-term – and the acceptability of cumulative and in-combination impacts – must be properly assessed taking into account each of the above stages of our Development’s life. Our Development requires that its operations, consents (including conditions), and any stakeholder agreements entered into by it are unaffected by MOWF. Our Development’s concerns include the following. Issue One: Following review of the ES, we seek engagement with MOWF to discuss a number of environmental concerns relating to ornithology and the cumulative impact assessment. We are not convinced that the assessments are robust and we require to analyse this further and engage with MOWF. Issue Two: The ES highlights extensive impacts on shipping and navigation and commits to stakeholder engagement (F2.7 at 7.14.1.1). We require to be involved in such engagement to ensure that our consents, agreements, and operations are not adversely affected by MOWF. Issue Three: We believe that MOWF will adversely affect the energy yield of our Development. Due to the proximity outlined in the above-referenced figure and table, there is the potential for MOWF to interfere with wind speed or direction at our Development causing reduction in energy output. This requires to be properly assessed and appropriately mitigated / compensated.